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Han Z, Zhao Y, L Y, Dong J, Deng G. [Ideas and Briefing about Regulatory Requirements for Laboratory Developed Tests in the US]. Zhongguo Yi Liao Qi Xie Za Zhi 2022; 46:534-537. [PMID: 36254482 DOI: 10.3969/j.issn.1671-7104.2022.05.012] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [MESH Headings] [Subscribe] [Scholar Register] [Indexed: 06/16/2023]
Abstract
As a special kind of in vitro diagnostic devices(IVDs), laboratory developed tests(LDTs) are of great significance to the development of clinical laboratories. This study aims to explore the regulatory requirements ideas of LDTs. By introducing the development of LDTs and the changing of regulatory requirements in the United States, combing the current regulatory framework and discussing relevant ideas in the regulatory requirements of LDTs.
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Affiliation(s)
- Zhaozhao Han
- Center for Medical Device Evaluation, NMPA, Beijing, 100081
| | - Yang Zhao
- National Medical Products Administration, Beijing, 100037
| | - Yunfeng L
- Center for Medical Device Evaluation, NMPA, Beijing, 100081
| | - Jinchun Dong
- Center for Medical Device Evaluation, NMPA, Beijing, 100081
| | - Gang Deng
- Center for Medical Device Evaluation, NMPA, Beijing, 100081
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Valla V, Alzabin S, Koukoura A, Lewis A, Nielsen AA, Vassiliadis E. Companion Diagnostics: State of the Art and New Regulations. Biomark Insights 2021; 16:11772719211047763. [PMID: 34658618 PMCID: PMC8512279 DOI: 10.1177/11772719211047763] [Citation(s) in RCA: 10] [Impact Index Per Article: 3.3] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [Track Full Text] [Download PDF] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 04/15/2021] [Accepted: 09/02/2021] [Indexed: 11/15/2022] Open
Abstract
Companion diagnostics (CDx) hail promise of improving the drug development
process and precision medicine. However, there are various challenges involved
in the clinical development and regulation of CDx, which are considered
high-risk in vitro diagnostic medical devices given the role they play in
therapeutic decision-making and the complications they may introduce with
respect to their sensitivity and specificity. The European Union (E.U.) is
currently in the process of bringing into effect in vitro Diagnostic Medical
Devices Regulation (IVDR). The new Regulation is introducing a wide range of
stringent requirements for scientific validity, analytical and clinical
performance, as well as on post-market surveillance activities throughout the
lifetime of in vitro diagnostics (IVD). Compliance with General Safety and
Performance Requirements (GSPRs) adopts a risk-based approach, which is also the
case for the new classification system. This changing regulatory framework has
an impact on all stakeholders involved in the IVD Industry, including Authorized
Representatives, Distributors, Importers, Notified Bodies, and Reference
Laboratories and is expected to have a significant effect on the development of
new CDx.
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Affiliation(s)
| | - Saba Alzabin
- Department of Oncological Science, Icahn School of Medicine at Mount Sinai, New York, NY, USA.,Elm Scientific Ltd., London, UK
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Moran JH, Kessler L, Moylan J, Forrest C, Boehme K, Kennedy J, Greninger A, Baird G, Olgaard E, James L. Modifying laboratory testing via home brew during the COVID-19 pandemic. J Clin Transl Sci 2021; 5:e93. [PMID: 34192050 PMCID: PMC8134902 DOI: 10.1017/cts.2021.5] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [Grants] [Track Full Text] [Download PDF] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 12/10/2020] [Revised: 01/12/2021] [Accepted: 01/13/2021] [Indexed: 11/07/2022] Open
Abstract
Rapid development and deployment of diagnostic testing for COVID-19 have been a key component of the public health response to the pandemic. Out of necessity, academic and other clinical laboratories developed laboratory testing innovations for COVID-19 to meet clinical testing demands. In addition to constraints on local testing supplies and equipment, a rapidly changing regulatory framework created challenges for translational scientists. Illustrative examples of approaches used to develop laboratory tests during the early stages of the COVID-19 pandemic demonstrate effective team science approaches to this challenging clinical care and public health emergency. These experiences and the associated lessons learned are relevant to the development of public health response plans for future pandemics.
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Affiliation(s)
- Jeffery H. Moran
- Departments of Pharmacology and Toxicology, Microbiology, Pathology, and Pediatrics, College of Medicine, University of Arkansas for Medical Sciences, Little Rock, Arkansas, USA
| | - Larry Kessler
- Department of Health Services, School of Public Health, University of Washington, Seattle, WA, USA
| | - Jennifer Moylan
- Department of Physiology, College of Medicine, University of Kentucky, Lexington, Kentucky, USA
| | - Craig Forrest
- Departments of Pharmacology and Toxicology, Microbiology, Pathology, and Pediatrics, College of Medicine, University of Arkansas for Medical Sciences, Little Rock, Arkansas, USA
| | - Karl Boehme
- Departments of Pharmacology and Toxicology, Microbiology, Pathology, and Pediatrics, College of Medicine, University of Arkansas for Medical Sciences, Little Rock, Arkansas, USA
| | - Josh Kennedy
- Departments of Pharmacology and Toxicology, Microbiology, Pathology, and Pediatrics, College of Medicine, University of Arkansas for Medical Sciences, Little Rock, Arkansas, USA
| | - Alex Greninger
- Department of Laboratory Medicine and Pathology, School of Medicine, University of Washington, Seattle, Washington, USA
| | - Geoff Baird
- Department of Laboratory Medicine and Pathology, School of Medicine, University of Washington, Seattle, Washington, USA
| | - Ericka Olgaard
- Departments of Pharmacology and Toxicology, Microbiology, Pathology, and Pediatrics, College of Medicine, University of Arkansas for Medical Sciences, Little Rock, Arkansas, USA
| | - Laura James
- Departments of Pharmacology and Toxicology, Microbiology, Pathology, and Pediatrics, College of Medicine, University of Arkansas for Medical Sciences, Little Rock, Arkansas, USA
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Johnson WG, Marchant GE. Legislating in the time of a pandemic: window of opportunity or invitation for recklessness? J Law Biosci 2020; 7:lsaa042. [PMID: 32959005 PMCID: PMC7337772 DOI: 10.1093/jlb/lsaa042] [Citation(s) in RCA: 3] [Impact Index Per Article: 0.8] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Key Words] [Track Full Text] [Subscribe] [Scholar Register] [Received: 04/20/2020] [Revised: 05/01/2020] [Accepted: 05/19/2020] [Indexed: 05/24/2023]
Affiliation(s)
- Walter G Johnson
- Sandra Day O’Connor College of Law, Arizona State University, Phoenix, AZ 85004, USA
| | - Gary E Marchant
- Sandra Day O’Connor College of Law, Arizona State University, Phoenix, AZ 85004, USA
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Lantuejoul S, Damotte D, Hofman V, Adam J. Programmed death ligand 1 immunohistochemistry in non-small cell lung carcinoma. J Thorac Dis 2019; 11:S89-S101. [PMID: 30775032 PMCID: PMC6353738 DOI: 10.21037/jtd.2018.12.103] [Citation(s) in RCA: 44] [Impact Index Per Article: 8.8] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 10/29/2018] [Accepted: 12/14/2018] [Indexed: 12/26/2022]
Abstract
Lung cancer is the leading cause of cancer death worldwide with low response rates to conventional chemotherapy. New promising therapies have emerged based on programmed cell death protein 1 (PD-1) immunity checkpoint inhibitors (ICI), including anti-PD-1, such as nivolumab and pembrolizumab, or programmed death ligand 1 (PD-L1) inhibitors, such as atezolizumab, durvalumab, and avelumab. The prescription of pembrolizumab has been approved by FDA and EMA for advanced stages non-small cell lung carcinoma (NSCLC), restricted for first-line setting to patients whose tumor presents ≥50% of PD-L1 positive tumor cells (TC), and ≥1% for second-line and beyond, leading to consider PD-L1 assay as a companion diagnostic tool for pembrolizumab. Very recently, the EMA has approved durvalumab for the treatment of patients with unresectable stage III NSCLC not progressing after chemoradiotherapy and whose tumors express PD-L1 on ≥1% of TC. Four standardized PD-L1 immunohistochemistry assays have been used in clinical trials; 22C3 and 28-8 PharmDx assays on Dako/Agilent platforms, and SP142 and SP263 assays on Ventana platforms, each test having been developed initially for a specific ICI. They differ in terms of primary monoclonal antibody, platform, detection system and scoring methods with different thresholds of positivity validated in clinical trials. Several studies have shown a close analytical performance of the 22C3, 28-8 and SP263 assays regarding TC staining in NSCLC, with poor concordance with SP142 assay and for immune cells. However, as dedicated platforms are not available in all pathology laboratories and because of the high cost of these assays, laboratory developed tests are widely used in many countries. Their validation must guarantee the same sensitivities and specificities as compared to standardized assays. Overall, PD-L1 test is of great help to select patients who could benefit for ICI and most pathologists have included this test in their daily practice for advanced stages NSCLC, besides ALK and ROS1 IHC.
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Affiliation(s)
- Sylvie Lantuejoul
- Département de Biopathologie, Centre Léon Bérard UNICANCER, Lyon, France
- Département de Recherche Translationnelle et d’Innovations, Centre Léon Bérard UNICANCER, Lyon, France
- Institute for Advanced Biosciences, Université Grenoble Alpes, Grenoble, France
- PATTERN: Group of French Thoracic Pathologists for Innovation and Translational Research, Synergie Lyon Cancer Foundation, Lyrican, France
| | - Diane Damotte
- PATTERN: Group of French Thoracic Pathologists for Innovation and Translational Research, Synergie Lyon Cancer Foundation, Lyrican, France
- Département de Pathologie, Hôpital Cochin, Assistance Publique-Hôpitaux de Paris, Paris, France
- Centre de Recherche des Cordeliers, Université Paris Descartes, Paris, France
| | - Véronique Hofman
- PATTERN: Group of French Thoracic Pathologists for Innovation and Translational Research, Synergie Lyon Cancer Foundation, Lyrican, France
- Laboratory of Clinical and Experimental Pathology, FHU OncoAge, Nice Hospital, University Côte d’Azur, Nice, France
- Biobank BB-0033-0025, FHU OncoAge, Nice Hospital, University Côte d’Azur, Nice, France
| | - Julien Adam
- PATTERN: Group of French Thoracic Pathologists for Innovation and Translational Research, Synergie Lyon Cancer Foundation, Lyrican, France
- Département de Biologie et Pathologie Médicales, Gustave-Roussy, Villejuif, France
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Abstract
Regulatory compliance in the direct-to-consumer genetic testing market is highly sophisticated as there are numerous federal, state, and ethical barriers to entry. In 2010, amid an underregulated market, 23andMe sought to do what few companies in the medical industry had attempted before-disregard the guidance and requests of the US Food and Drug Administration. This regulatory strategy effectively destined the company's Personal Genome Service for failure; however, the company changed course and has been granted several regulatory clearances. This exemplifies the importance of a healthy relationship with regulatory agencies, although challenges remain. The DTC industry continues to have a perplexing regulatory framework at both the federal and state level. There are also ethical concerns with the monetization of deidentified genetic health information, as genetic data have an inherent level of identifiability and are not fully protected by the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule in these scenarios. Although some DTC tests are now cleared in the United States, the concern that a learned intermediary is needed for interpretation of results remains. The regulatory oversight of this market will need to continue to develop to ensure the protection of consumer health and privacy.
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Affiliation(s)
- Brendan Seward
- 1 Johns Hopkins University, Employee at Clarius Mobile Health Corp, Surrey, British Columbia, Canada
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